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gov.uscourts.azd.941986.1.0.pdf


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Case 2:15-cv-01768-DJH Document 1 Filed 09/03/15 Page 3 of 19

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subject to threats and extortion. The defendants are the website operators and Internet

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Service Providers who are hosting the stolen data to facilitate public searches, often for a

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fee. Through this action, Plaintiffs allege civil receipt of stolen property under California

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law, violation of California’s Unfair Competition Law, intentional and negligent infliction

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of emotional distress, and violation of the Computer Fraud and Abuse Act, 18 U.S.C. §

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1030 on behalf of Plaintiffs John Doe 1 through 3 and against GoDaddy.com, LLC

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(“GoDaddy”), Amazon Web Services, Inc. (“Amazon”), and Roes 1 through 20

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(collectively, the “Roe Defendants”).

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JURISDICTION AND VENUE
6.

This Court has subject matter jurisdiction over Plaintiffs’ federal Computer

Fraud and Abuse Act, 18 U.S.C. § 1030.
7.

This Court has supplemental jurisdiction of Plaintiffs’ state law claims

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pursuant to 28 U.S.C. § 1367(a) in that these state law claims are so related to the

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Computer Fraud and Abuse Act claim raised in this Complaint that they form part of the

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same case or controversy under Article III of the United States Constitution.

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8.

Alternatively, this Court has subject matter jurisdiction under 28 U.S.C. §

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1332 because the matter in controversy exceeds the sum or value of $75,000, exclusive of

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interest and costs, and the action is between citizens of different states. To wit, Plaintiffs

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are citizens of and domiciled in California, New Jersey, and Maryland, while Defendants

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are citizens of and domiciled in Delaware and Arizona.

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9.

Venue is proper under 28 U.S.C. § 1391 because many of the incidents,

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events, or omissions complained of and giving rise to the instant claims and controversy

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occurred within the State of Arizona and this District.

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10.

This Court has personal jurisdiction over Defendants because Defendants,

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and each of them, do substantial business in Arizona and purposefully direct substantial

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activities as the residents of Arizona by means of the Internet services and websites

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described herein. Defendants, and each of them, have done substantial and continuous

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business with Arizona residents and have purposefully directed substantial and pervasive
Case No.

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COMPLAINT